Commonwealth v. Beneficial Finance Co.
Massachusetts Supreme Judicial Court
275 N.E.2d 33 (1971)
Two individuals connected to Beneficial Finance's parent company, though not formally Beneficial's own employees, bribed state officials to secure favorable treatment, and the payments involved substantial disbursed funds ($25,000) unlikely to have come from an individual's own pocket rather than as a matter of corporate policy; Beneficial (defendant) was convicted based on jury instructions asking whether the employees' illegal acts "constituted" the corporation's own act, without requiring proof the board of directors specifically authorized the bribery.
Whether a corporation can be held criminally liable for the actions of its employees if those employees are placed in a position of authority to act for, and on behalf of, the corporation in handling particular corporate business.